N357708

N357708 January 28, 2026 CLA-2-87:OT:RR:NC:N2:206 CATEGORY: Classification TARIFF NO.: 8708.70.6060 Kristen Morneau OCEANAIR, Inc. 5 Centennial Drive Peabody, MA 01915 RE: The tariff classification of skidder tracks from Czech Republic Dear Ms. Morneau: In your letter dated January 12, 2026, you requested a tariff classification ruling on behalf of Wallinfords Inc. A representative sample was supplied with your request. The articles under consideration are five models of skidder tracks: Bluetrack Duo Perfect - BTP, Bluetrack Duo Duro - BTD, Bluetrack Duo Flow - BTF, Bluetrack Duo Flow-Perfect - BTFP, and Mono Skidder - PTMSTFP, which are used on the wheels of harvesters, forwarders, and skidders. You state that the terrain in a forestry environment is unpredictable, requiring strong traction. As such, the tracks are made specifically for extreme applications. They are studded, made of steel and can be adjusted in length for the specific vehicle. Although each model is designed for a specific vehicle, all models are similar in their features and applications. All Duo models cover two wheels at a time, while the Mono skidder covers one wheel at a time. You have suggested that the forestry tracks should be classified as parts of forestry machinery under heading 8436, Harmonized Tariff Schedule of the United States (HTSUS). The courts have considered the nature of “parts” under the HTSUS, and two distinct tests have resulted. See Bauerhin Technologies Limited Partnership, & John V. Carr & Son, Inc. v. United States, 110 F.3d 774, 779 (Fed. Cir. 1997). The first, articulated in United States v. Willoughby Camera Stores, 21 C.C.P.A. 322 (1933), requires a determination of whether the imported item is “an integral, constituent, or component part, without which the article to which it is to be joined, could not function as such article.” Bauerhin, 110 F.3d at 778 (quoting Willoughby Camera, 21 C.C.P.A., at 324). The second, set forth in United States v. Pompeo, 43 C.C.P.A. 9 (1955), states that an imported item “dedicated solely for use” with another article is a part of that article provided that, “when applied to that use,” the article will not function without it. Pompeo, 43 C.C.P.A., at 14. Under either line of cases, an imported item is not a part if it is “a separate and distinct commercial entity.” ABB, Inc. v. United States, 28 Ct. Int’l Trade 1444, 1452-53 (2004); Bauerhin, 100 F. 3d, at 1452-32. The information you submitted, along with our research on your product, indicates that the forestry tracks are optional equipment that are accessories rather than parts. We further note that the forestry tracks are not solely used with machinery classified within heading 8436, HTSUS. As there is no tariff provision for accessories in heading 8436, HTSUS, and the forestry tracks can also be used with machinery classified in other headings of the nomenclature, your suggested classification is inapplicable. Furthermore, the pictorial diagrams submitted with your request depicted vehicles of Chapter 87, HTSUS, specifically heading 8701, HTSUS. Since the principal use of the tracks is on vehicles of heading 8701, HTSUS, the tracks will be classified as an accessory to those vehicles. The applicable subheading for the five models of skidder tracks, Bluetrack Duo Perfect - BTP, Bluetrack Duo Duro - BTD, Bluetrack Duo Flow - BTF, Bluetrack Duo Flow-Perfect - BTFP, and Mono Skidder - PTMSTFP, will be 8708.70.6060, HTSUS, which provides for “Parts and accessories of the motor vehicles of headings 8701 to 8705: Road wheels and parts and accessories thereof: For other vehicles: Parts and Accessories: Other.” The applicable duty rate will be 2.5 percent, ad valorem. The duties cited above are current as of this ruling’s issuance. Duty rates are provided for your convenience and are subject to change. The text of the most recent HTSUS and the accompanying duty rates are provided at https://hts.usitc.gov/. This ruling does not address the applicability of any additional duties, taxes, fees, exactions and/or other charges, which may apply to the goods discussed herein. This includes, but is not limited to, tariffs and other duties as provided for in Subchapter III to Chapter 99, HTSUS. Thus, for example, in addition to the classification stated above, the merchandise covered by this ruling may also need to be reported with either the Chapter 99 provision under which an additional tariff applies or one of the Chapter 99 provisions covering exceptions to such tariffs. For further information to assist with the importation process, please refer to the frequently updated Cargo Systems Messaging Service (CSMS) messages at https://www.cbp.gov/trade/automated/cargo-systems-messaging-service and Frequently Asked Questions on the Trade Remedy/IEEPA page at https://www.cbp.gov/trade/programs-administration/trade-remedies/IEEPA-FAQ. The holding set forth above applies only to the specific factual situation and merchandise description as identified in the ruling request. This position is clearly set forth in Title 19, Code of Federal Regulations (CFR), Section 177.9(b)(1). This section states that a ruling letter is issued on the assumption that all of the information furnished in the ruling letter, whether directly, by reference, or by implication, is accurate and complete in every material respect. In the event that the facts are modified in any way, or if the goods do not conform to these facts at time of importation, you should bring this to the attention of U.S. Customs and Border Protection (CBP) and submit a request for a new ruling in accordance with 19 CFR 177.2. Additionally, we note that the material facts described in the foregoing ruling may be subject to periodic verification by CBP. This ruling is being issued under the provisions of Part 177 of the Customs and Border Protection Regulations (19 C.F.R. 177). A copy of the ruling or the control number indicated above should be provided with the entry documents filed at the time this merchandise is imported. If you have any questions regarding the ruling, please contact National Import Specialist Liana Alvarez at liana.alvarez@cbp.dhs.gov. Sincerely, (for) Denise Faingar Designated Official Performing the Duties of the Division Director National Commodity Specialist Division

set forth above applies only to the specific factual situation and merchandise description as identified in the ruling request. This position is clearly set forth in Title 19, Code of Federal Regulations (CFR), Section 177.9(b)(1). This section states that a ruling letter is issued on the assumption that all of the information furnished in the ruling letter, whether directly, by reference, or by implication, is accurate and complete in every material respect. In the event that the facts are modified in any way, or if the goods do not conform to these facts at time of importation, you should bring this to the attention of U.S. Customs and Border Protection (CBP) and submit a request for a new ruling in accordance with 19 CFR 177.2. Additionally, we note that the material facts described in the foregoing ruling may be subject to periodic verification by CBP. This ruling is being issued under the provisions of Part 177 of the Customs and Border Protection Regulations (19 C.F.R. 177). 

A copy of the ruling or the control number indicated above should be provided with the entry documents filed at the time this merchandise is imported. If you have any questions regarding the ruling, please contact National Import Specialist Liana Alvarez at liana.alvarez@cbp.dhs.gov. 
Sincerely,
 (for) Denise Faingar Designated Official Performing the Duties of the Division Director National Commodity Specialist Division